Party Discovery: Diagnostic Imaging Consultants Of St. Petersburg, P.A.,ESCOTO, ARNULFO vs 21St Century Centennial Insurance Company

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                                Filing # 125866954 E-Filed 04/29/2021 02:55:14 PM


                                  IN THE COUNTY COURT OF THE 13th JUDICIAL CIRCUIT
                                       IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

                DIAGNOSTIC IMAGING CONSULTANTS                                          CASE NO.:               21-CC-032259
                OF ST. PETERSBURG, P.A. D/B/A                                           DIV:                    K
                DIAGNOSTIC IMAGING CONSULTANTS,
                         as assignee of Arnulfo Escoto
                         Plaintiff,

                vs.

                21ST CENTURY CENTENNIAL
                INSURANCE COMPANY,
                         Defendant.
                ______________________________________/

                             PLAINTIFF’S SECOND REQUEST FOR PRODUCTION RE: LIMITING

                         COMES       NOW,     the  Plaintiff, Diagnostic    Imaging    Consultants    of  St. Petersburg,   P.A.   d/b/a

                Diagnostic Imaging Consultants, by and through undersigned counsel, pursuant to Rule 1.350, Florida

                Rules of Civil Procedure and Small Claims Rule 7.020, hereby requests the Defendant, 21st Century

                Centennial Insurance      Company, to     produce the items      and matters hereinafter     set forth  for  inspection

                and/or copying at the offices of the undersigned counsel within thirty (30) days after service hereof:

                         1.       Please   provide    all documentation      Defendant     intends   to rely   on  to  prove   that  the
                applicable   fee  schedule   under   Medicare     to be  applied    to Plaintiff’s  bills  for services   provided    to
                Arnulfo Escoto on 5/2/2016 was based on the participating physicians schedule under Medicare Part
                B as opposed to the limiting charge under Medicare Part B for 2007.


                         It is hereby requested that the aforesaid production be made within thirty (30) days from the
                date of service at The Physician Collections Group, P.A., 701 S. Howard Ave., Ste 106-391, Tampa,
                Florida 33606.




4/29/2021 2:55 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
                                                         CERTIFICATE OF SERVICE

                I HEREBY        CERTIFY       that  a true and   correct copy    of the forgoing     was   electronically   served via
                the  Florida   Courts   E-Filing   Portal,  on   Melissa   A.  Mears,    Esq.,  daviepip@farmersinsurance.com,
                Law Offices of Sanabria & Marsh - PIP Unit, P.O. Box 258829, Oklahoma City, OK 73125-8829,
                on April 29, 2021.




                                                                               Lorca J. Divale - FBN: 0173622
                                                                               The Physician Collections Group, P.A.
                                                                               701 S. Howard Ave., Ste 106-391
                                                                               Tampa, Florida      33606
                                                                               (813) 600-3029; LorcaDLG@gmail.com
                                                                               Attorneys for the Plaintiff




4/29/2021 2:55 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2